Part B.

Public Comments to the Environmental Assessment

Comment:   Support for Alternative 2.  There have been many successful lime treatments in Virginia and West Virginia, with no none negative impacts.

Response:   The Decision Notice documents which alternative was selected. Alternative 2 can be selected by the Regional Forester if she feels it best meets the need of the project.

Comment: There is essentially no likelihood of restoration to a "naturally functioning ecosystem",  multiple liming operations will probably be required, frequent monitoring (more than once per year) is the proper management action, and liming will not solve all problems stemming from acid deposition.

Response: The agency agrees.

Comment:   The Forest Service should expect and plan now to repeat the liming process at St. Mary's in the near future (based on continued monitoring), rather than leave the impression with anyone that a single application is likely to solve the problem.

Response: The EA, page 3, clearly states that "If air quality does not improve and acidification does not decrease, the project could need to be repeated in 5 to 10 years to maintain the indigenous aquatic life in the St. Mary's Wilderness." Yet, we are not making a decision at this time on any future projects. Future projects will be proposed following monitoring and evaluation of such factors as water chemistry (ph, acid neutralizing capacity, and calcium), and fish and benthic macroinvertebrates,

Comment:   The aquatic elements of the St. Mary's are so seriously degraded by human activity (atmospheric pollution and acid deposition) that the term "wilderness" as it is commonly used (as opposed to an official designation) can hardly be applied.

Response: The agency respects the opinion of the author.

Comment: Natural processes in St. Mary's are already disrupted and the river cannot serve as a "control" area free of human intervention. We might consider changing the status of St. Mary's to some sort of management area, rather than continuing to refer to it as a wilderness area, free of human impacts. We might consider searching for a replacement for St. Mary's as a wilderness.

Response: The agency respects the opinion of the author. The changing of the Wilderness designation is beyond the scope of this project, but identifies a potential problem that may be considered in future wilderness recommendations by the agency: that of looking beyond National Forest boundaries to determine human sources of disruption to natural processes.

Comment:   Issue 4 is somewhat confusing.  I would not advocate introducing exotic (and acid-sensitive) brown and rainbow trouts. If they reestablish on their own, we could consider removing them during routine fish population surveys, or allow fisherman to take them.

Response: The agency agrees. We are not advocating the introduction of exotic species. The EA, pages 18 and 19, discusses brown and rainbow trout.  As noted in the EA (page 19), any non-indigenous fish found during the monitoring period will be removed.  Likewise, as suggested by the author, these removals could also occur during during routine fish population surveys or through fishing.

Comment:   FS proposal to lime most of major tributaries may minimize the mixing zone phenomenon. However, mixing zones may potentially result at streamside when acidified, aluminum-rich soil-water meets limed stream water. This may be minimized by whole watershed liming, which is rarely feasible.

Response:   Monitoring will help reveal whether the mixing zones exist and if so, what effect they had on the aquatic organisms. The Forest Service is not analyzing whole watershed liming.

Comment: If precipitated aluminum is retained locally, then re-dissolution of amorphous aluminum can occur during acidic episodes.

Response: The agency agrees. Yet, in a letter to this agency, Mr. Bernard Dowler, Chief of the Wildlife Section of the West Virginia Department of Natural Resources states that "A study of Dogway Fork of the Cranberry River, West Virginia found no significant increase in aluminum concentrations in stream gravel below treatment.  Native brook trout spawn successfully directly below treatment attesting to the fact that aluminum is not adversely impacting trout populations.

Comment:   I encourage the agency to monitor water chemistry at multiple locations in the river more frequently than once per year. I suggest a minimum of quarterly monitoring throughout the basin, and weekly monitoring at a downstream site.

Response:   The EA, page 6, only states that monitoring will occur for a minium of three years. There was never any intention to imply that monitoring would only occur once each year.  The agency will consider the author's recommendations in development of its detailed monitoring plans.  Yet, with limited funds, we must point out that weekly monitoring may not be realistically feasible.

Comment:   The "Total monomeric Aluminum in stream water" (EA, page 7) needs to be better defined.  If this refers to baseflow levels,  30 ppb is not a desirable endpoint; it must be lower, to produce a healthy fish community and sustainable fishery.

Response:   Fish are only one of the many organisms were are trying to restore. Liming is also intended to restore the macroinvertebrate community, which has experienced a 38% loss of taxa (EA, page 2) . Commentator has not provided the agency with a "ppb" level for the agency to consider.  The "total monomeric aluminum in stream water" estimate of 40 ppb under the no action alternative 1 is from the 1996-1997 sampling data at the downstream wilderness boundary.  During this time total monomeric aluminum values ranged from 12 ppb to 40 ppb.  Rather than averaging, the highest value was used in the analysis to give a worst case scenario.

The "total monomeric aluminum in stream water" estimate of 30 ppb under alternative 2 is an estimate of expected decrease post liming.  This value was derived after looking at the decreases in aluminum that were realized in various liming projects in WV and VA.  Generally, the greater amount of aluminum present prior to liming, then the greater the decrease in aluminum post-liming.

Monomeric aluminum makes up only a fraction of the total aluminum present. Additionally, the total monomeric portion is broken into inorganic and organic monomeric aluminum.  The total monomeric aluminum usually comprises about 1/2 of the total aluminum. Liming has been shown to decrease the monomeric portion of the equation.  Thus, even if the total aluminum did not change post liming, the monomeric portion of that has been shown to have significant decreases.  This is important, since it is the monomeric portion, specifically, the inorganic monomeric aluminum that is especially toxic to aquatic biota.

Total aluminum values less than 100 ppb are not generally considered to be a threat to aquatic life. Once values climb higher toward 150 ppb, then concern about aluminum toxicity is raised.

The underlying bedrock from the Antietam formation is known to have low solubility and also relatively low amounts of aluminum present. Therefore, one would not expect to have extremely high levels of aluminum in water coming from watersheds with this geology.

Comment:   I am still concerned about potential accumulation of aluminum precipitate when liming is conducted on a long-term basis.

Response:   The agency respects the opinion of the author.

Comment: A detailed monitoring plan the should be designed and subjected to external review before a final decision is made. It should include the following objectives:  1) to quantify the short and long-term effectiveness of the limestone treatment for stream neutralization under the range of flow conditions, 2) to detect potential problems associated with aluminum dynamics in both the stream channel and the riparian water table, and 3) to monitor the actual acid-base status of the watershed, establishing background conditions for assessment of treatment results and future treatment necessity.

Response:   The decision on this project is not dependant on the formulation of a peer-reviewed monitoring plan, but dependant on analysis of the potential project impacts. A detailed monitoring plan will be developed once the decision is made on whether the proposal will be implemented.  The agency will consider the author's recommendations in development of its detailed monitoring plans.

Comment: Our agency and some constituent groups are interested in assisting you in the implementation of this project. Virginia Power is willing to underwrite the cost of the helicopters.

Response:   This agency is grateful for the assistance of other federal and state agencies, as well as private individuals, industry, and groups.  Your assistance will drastically reduce federal funding needed to complete this project.

Comment:   Our data indicates that St. Mary's now contains only one significant year class of brook trout which are currently two years of age. The highest reproductive potential for this year class is this year, although a large number of fish will remain for next season. It is imperative that liming occur as soon as possible to insure viability of the fish populations and generic strains currently in the river.

Response: We agree.

Comment: If we did assume aluminum concentrations build up at the point of neutralization, it must be remembered that this process is already happening somewhere downstream in the ST. Mary's River of its receiving stream where higher alkalinity is encountered. The proposed treatment would simply move this point upstream to the treatment sites where aquatic life have already been killed by low pH.  What harm would be done?

Response:   We agree, no harm would be done since nothing would exist to harm.

Comment:   The late Ernie Dickerman, Gerry Schuder, Congressman Jim Olin, and myself (Corbin Dixon) spearheaded the effort to establish the wilderness condition thinking it would afford the ultimate protection to this unique and valuable trout stream which was the premier trout stream in Augusta County. We were wrong.

Response:   Thanks for providing a historical perspective. The agency respects the author's comments.

Comment:   The destruction of St. Mary's is man made and any reference to "natural processes" should be eliminated from consideration.

Response:   The agency respects the opinion of the author.

Comment:   The Forest Service should start acquiring or cause to be fabricated a multi ton aluminum bucket for this use in this project.  Not having one should not be used as an excuse for further delays.

Response:   We're working on it.

Comment:   Another buzz word is "wilderness experience". Since when does a dead stream contribute to a wilderness experience? I can only find this experience when I view the fish, mink, otters, crayfish, mayflies, and other denizens of a healthy stream.  You'll find that proponents of "wilderness experience" are anti-consumptive to the use of our public lands.  They just don't want to see fishermen on a stream.  ...now these wilderness proponents have turned their backs on the original concepts. I've heard individuals say they wished the stream would go completely dead.

Response:   The agency respects the opinions of the author.

Comment:   Liming need not be visible in any way.  It is not necessary to create piles of limestone, just deposit it either in the stream or adjacent to it in any fashion.

Response:   Regardless of the method, limestone will contrast with the surrounding natural vegetation and soil and be visible to those visitors who happen upon the dumping sites.

Comment:   I don't see the need of cutting trees for the application.

Response:   Dumping sites with openings in the tree canopy were chosen (EA at page 10).  All effort will be made to leave trees at the dumping sites.  The helicopter pilot will be encouraged to do a test run with empty bucket before trees are felled. Trees will be removed if the pilot feels they will cause a safety problem to him or herself; i.e. because the bucket may hang up and cause the helicopter to crash. 

Comment:   The dilemma of aquatic ecosystems in wilderness areas dying from human-induced acid rain is a complex and difficult problem.  Although we do not want to see St. Mary's River die, we think the best solution is to attack the problem at its source.  Any other management action will be only a temporary "band-aid".  We remain opposed to using helicopters to lime the St. Mary's River within federally designated Wilderness for the following reasons:

1 Liming is human intervention that is not appropriate in Wilderness.

2 Liming St. Mary's River does absolutely nothing to decrease air pollution at the source.  This intervention may lead the public and our government to believe that liming will fix the problem, thereby delaying efforts to decrease air pollution.

3 This intervention will set a bad precedent for Wilderness areas.

4 A project of this magnitude will be a disruption to the solitude so many people enjoy in St. Mary's Wilderness.

5 The piles of limestone will degrade the visual quality of the area.

6 One purpose of Wilderness areas is to allow scientists to study natural areas where man has not intervened.  We need some areas that we can monitor over time to see how the forest and streams respond without intervention.  It would seem that Wilderness areas should be saved for this purpose.

7 We remain concerned that liming may actually increase aluminum poisoning of stream life during high-flow conditions.

8 This expensive project will delay a decline in stream health for only 5 years. Then another equally expensive treatment will have to be administered. This must go on forever, or until acid rain decreases.  There is no guarantee that money will be available in the future.

9 The 3 years of annual monitoring described in the EA is inadequate to determine the effects of liming.

10 A precedent-setting action of this magnitude in a Wilderness area absolutely requires an Environmental Impact Statement.

Response:     The Decision Notice documents which alternative was selected. The No Action Alternative 1 can be selected by the Regional Forester if she feels it best meets the need of the project.   Across the nation, numerous projects have occurred in designated wilderness in the past.

Comment:   Limestone dumping sites may be near locations of federally-listed swamp pink, yet it is difficult to tell the exact relationship of the sites due to the scale of the maps. Can you send a 1:24,000 scale map locating the application sites so that we can more appropriately review this project?  We would also like to review a copy of the Biological Evaluation since the EA does not address swamp pink concerns in detail.  Does the BE specifically identify those areas surveyed.

Response:   A map has been sent to the consulted, cooperating agency as requested. Swamp pink is known to occur adjacent to the St. Mary's River about 500 feet downstream from one lime dumping site.  The dumping sites were chosen according to terrain and the presence of natural openings, thus allowing the helicopter maximum maneuverability for safety, while minimizing the impacts to existing, standing vegetation. The EA, Appendix A, page 24, discusses the swamp pink.  Based on field inventories and the Biological Evaluation, the agency determined that there was no significant issue surrounding swamp pink that would guide development of alternatives or mitigation measures in the EA. The 6/24/98 BE, page 2 states that the swamp pink is known to be in the wilderness area, but its habitat is not in streams. Yet, the BE does also states that since the project is designed to bring the pH of the water closer to what it historically was (pH of 6.8 from EA page 2), there will be no adverse impacts if the treated water should enter a swamp pink site due to a flood event.  Clarifying this, there will be "no effect" because 1) swamp pink is known to live in pH as high as 7.0 in Cold Springs Branch, which is about 2 miles west of the project area, and 2) there's no evidence of past flood events in the plant's area as the stream channel nearest the swamp pink is deeply incised with the plant located 6-7 feet higher than the water.    After the project is completed, we estimate that stream's pH will continue to be in the natural range of pH variability that swamp pink is currently known to occur in.  The BE has been amended to clarify this situation.  Additionally, the Forest informally consulted with Andy Moser and Lisa Arroyo of the U.S. Fish and Wildlife Service (USFWS) regarding this project and its effect on the swamp pink. The USFWS agreed that there will be no effect on the swamp pink.

Comment: There is the potential for swamp pink to be adversely affected if lime were deposited into the wetlands supporting swamp pink during storm events.  A dramatic or rapid increase in the pH in swamp pink habitat may adversely impact the species. The application site should be moved downstream of known populations.

Response:   The agency disagrees. Commentator has provided no research or other evidence to support this statement.  First, swamp pink is abundant in an adjacent drainage (Cold Spring Branch) where the pH has been measured at 7.0.  At a monitoring station near a swamp pink location, , the pH is about 4.5. During a storm, the agency estimates that the lime at this site may raise the pH to 5; thus the stream's pH will continue to be in the natural range of pH variability that swamp pink is currently known to occur in.

Secondly, the dumping site is about 500 upstream from the plants.  The lime sand will be transported to the site by helicopter carrying a bucket. The bucket will be about five feet above the stream at the time of release and the lime sand will be released by a person on the ground, thus there will be no chance that lime sand will accidently be released on the distant plants.

Thirdly, the lateral distance from the stream to the plants is about 50 feet.  There's no evidence of past flood events in the plant's area as 1) the stream channel nearest the swamp pink is deeply incised with the plant located 6-7 feet higher than the water (stream bed) and 2) there's no evidence of bedload being transported out of the bank at the plant's location.  Given the plant's location high in the upper reaches of the watershed, it would take a tremendous storm event to cause the stream to flood the plant population.  Then even if a flood event were to occur, and the limestone sand were to move out of the stream channel, the sand would be spread over a large area and be transported far downstream; it would not move all at once to the same spot.  (From the liming that has been done on Forest within the past ten years, the limestone sand is moved downstream in the channel during storm events, it does not typically move out of the channel.)  The U.S. Fish and Wildlife Service "Swamp Pink Identification Guide" states that this plant is found in areas that are perennially wet with the water table at or near the surface and having only slight fluctuations in water levels throughout the year. Thus, we suggest that they are relatively unimpacted by even storm events and flooding. These plants are more likely to be damaged by objects such as boulders or tree limbs than by increased pH levels.

Lastly, the seep where the plants grow has a continuous flow from the upland area toward the stream. This surface flow is more important to the plants than the water in the stream.  If an unlikely flood event moved water treated by the project to the plants, the pH would be lower than during lower flow periods due to the diluting effect of the storm water.

Thus, there will be no effect on the swamp pink and no need to seek out and inventory another site downstream of known populations.

Comment: The FWS and himself should have been contacted during EA preparation.

Response: FWS is not consulted unless a may affect determination is made.  For the state, we generally coordinate through VDGIF and DNH regarding state listed species.